Identifying the right customers
This formal guidance for remote gambling operators is not current and from 12 September 2022 operators are no longer required to take it into account. It was published in July 2019 and remained in effect from 31 October 2019 to 11 September 2022.
Following our consultation on customer interaction, Social Responsibility Code Provision 3.4.3 for remote gambling operators has been introduced and the majority of requirements are in effect from 12 September 2022. We issued this update on the regulatory requirements and status of formal guidance regarding customer interaction for remote gambling operators. The guidance issued in June 2022 under Social Responsibility Code Provision 3.4.3 is not in effect and is subject to further consultation. Operators are not required to take it into account.
You need to know:
- the types of markers and behaviours that could indicate harm relevant to online gambling, and
- how to spot when those indicators should trigger an interaction.
You need to put together what you know about the customer, with the relevant indicators of harm, to decide whether you need to interact. More knowledge about what to look for, with effective processes for monitoring customer behaviour, can mean quicker and better-informed decisions.
Some indicators of harm, such as high staking behaviour, can look similar to VIP and high-value customer activity. Even if you think the customer can afford it, they may still be experiencing gambling harms. Your enhanced contact with your VIPs means you have many opportunities to get to know them well and make better informed decisions.
We expect you to:
- use a range of indicators relevant to your business. Do not rely on financial indicators alone. You should use realistic thresholds and trigger points, and remember that not every customer who is experiencing or at risk of harm will trigger every indicator
- monitor customer activity so that you are able to interact early and quickly. Invest in systems and staff to manage your customer interaction process effectively
- monitor customer accounts from the time that they are opened
- make sure your process keeps pace with any increase in demand – through growth, mergers or other internal changes.
- train your staff to know their roles and responsibilities, and ensure they are supported and able to act promptly when they spot or are alerted to indicators of harm. This includes your VIP teams.
- aim to minimise the risk of harm for customers, whatever time of day they play, as well as for new customers
- take safer gambling seriously for all customers, including VIPs, and not let commercial considerations override customer protection. This means your VIP customers get the same level of protection as your other customers
- make meaningful records of all interactions with customers. Make these records available to staff and use them to aid decision-making. This should also take place in circumstances where an interaction has been ruled out e.g. because the customer is displaying signs of agitation
- even if you think your sector is “lower risk”, all forms of gambling present risks and you should understand the prevalence of gambling harms for the type of gambling products you offer and implement appropriate processes.
- actively promote and encourage the use of gambling management tools to all customers, and in particular where you have carried out a customer interaction. Research (Behavioural Insights Team, 2018) has shown that reducing friction in applying a gambling management tool leads to increased numbers taking it up.
Customer interaction: formal guidance for remote gambling operators Next page
Understanding the impact of gambling harm
Last updated: 15 September 2022
Show updates to this content
- Information in the callout at the beginning of the guidance page has been updated.